A Chaotic and Opaque Public Review Process for Link5G Towers

Letter to City Council Committee on Technology Chair Jennifer Gutierrez

June 6, 2023

Jennifer Gutierrez
New York City Council
City Hall
New York, NY 10007

Dear Chair Gutierrez,

MAS is pleased that the New York City Council Committee on Technology is holding an oversight hearing on the installation of new 32-foot tall Link5G towers across the city. We have heard from many constituents raising concerns about the poor design of these oversized installations, their adverse effect on our streetscapes, and the chaotic and opaque review process for their approval.

The City’s Office of Technology & Innovation (OTI) should provide the City Council with a public update on the project, including (1) clarification of the process for identifying and approving locations for Link5G towers, including (a) which city agencies must review them, (b) what agency approvals they have received and what were the conditions of these approvals, (c) how the borough presidents are informing residents of the installations, and (d) how communities have been able to provide feedback on installations in their areas; (2) a detailed list of the siting requirements and siting conditions imposed by all city agencies, with representative illustrations; (3) a list of Link5G installations to date, with equity districts noted; and (4) maps showing all installations to date at the borough, neighborhood and street scale.

Download Testimony

A Link5G tower at Bedford Avenue and Montgomery Street in Crown Heights, Brooklyn. Photo: Wikimedia Commons, Tdorante10. Modifications: photo cropped.

Design

The Link5G structures are poorly designed and oversized. Instead of a holistic new design for 5G infrastructure, the city has taken a piecemeal approach. The 5G towers have been forced into the existing LinkNYC design, resulting in a clunky structure sandwiched between signage panels.

The towers are out-of-scale for many residential and commercial areas, especially where narrow sidewalks and lower-scale buildings are prevalent. Link5G will clutter the city’s streetscapes, which are already host to many competing uses, resulting in impeded pedestrian flow and blocked views.

Process

The Public Design Commission (PDC) has binding jurisdiction on the design, and approved the installations in limited districts (commercial, commercial overlay, and manufacturing) with strict siting requirements. While reviewing the expansion of the program to residential and historic districts in September 2022, PDC Commissioners asked whether the visual impact could be reduced. They pressed OTI and vendor CityBridge to return to the PDC with a global design comparison, but that has not occurred in a public meeting.

According to the City’s presentations to the PDC, Link5G installations in historic areas require review and approval of the Landmarks Preservation Commission (LPC) and installations adjacent to public parks require review and approval of the Department of Parks & Recreation (DPR). It is unclear if any of these reviews have taken place to date and how they will be administered transparently.

Overall, the review process for the initial installations has been piecemeal and confusing, leading to uneven or nonexistent community engagement, and a lack of clarity on the full effects of 5G towers across the City.

The Federation Communications Commission has only now undertaken the required historic preservation review (106 Review) for this project in New York City. The Nationwide Programmatic Agreement under which the review will take place seems at first blush to be ill-suited for a project that could potentially effect neighborhoods in every part of the city.

It is also unclear whether the Environmental Assessment for the project was undertaken.

Equity

MAS supports the stated goal of bridging the digital divide and providing wireless and cellular services to underserved communities, but the City has not demonstrated how the initial roll-out will achieve this goal. The City claimed that no installations would be made in Manhattan’s core until after installations in high-need neighborhoods have been completed. And yet, the Upper East Side and SoHo have been selected for an initial roll-out of new towers. Furthermore, don’t our lower-income neighbors also deserve well-designed streetscape structures?

There are additional questions about the financing of the towers, which ones will have advertising screens, which ones will replace the older, obsolete kiosks, and where the new towers will be distributed across the entire city.

We urge the City Council to seek answers to all of these questions about the new 5G towers.

Yours truly,

Elizabeth Goldstein Signature